Moving for a Protective Order. Naturally, defense counsel will then be playing from behind in drafting an opposition and attempting to reframe the issues. (Code Civ. If you wait too long and finally realize at the time of expert discovery that they did not produce this information, it may be too late for you to correct the error. To the extent that an agreement cannot be reached, the lawyer should immediately move for a protective order from the court. Ms. Sedrish devotes her free time in educating and promoting women in the law, and serves on the Boards of CAALA and CAOC, andis a member of AAJ. When defense attorneys refuse to disclose this information during the initial discovery stages, they are hoping you fail to thoroughly review their discovery responses. The deposition officer may not suspend the taking of testimony without the stipulation of all parties present unless any party attending the deposition, including the deponent, demands that the deposition officer suspend taking the testimony to enable that party or deponent to move for a protective order under Section 2025.420 on the ground that Welcome to FindLaw's Cases & Codes, a free source of state and federal court opinions, state laws, and the United States Code. Often times, the defense lawyer will object to the deposition and meet and confer with plaintiffs counsel. In California, deponents who do not want to submit to an in-person deposition due to health concerns can object and file a motion for a protective order. These cookies ensure basic functionalities and security features of the website, anonymously. 111, 733 S.E.2d 412 (Ga.App. These cookies help provide information on metrics the number of visitors, bounce rate, traffic source, etc. They consistently refuse to provide information regarding insurance coverage or to produce copies of declaration pages in response to corresponding requests for production without plaintiffs first entering into a protective order regarding this information. Universal Citation: CA Civ Pro Code 2025.420 through (2015) Leg Sess 2025.420. Section 2025.420 - Motion for protective order (a) Before, during, or after a deposition, any party, any deponent, or any other affected natural person or organization may promptly move for a protective order. A party seeking a protective order must make a reasonable and good faith attempt at an informal resolution of each issue presented by the motion for protective order. Magistrate Judge Koppe disagreed, explaining that: An oral deposition; (2) A written deposition; and (3) A deposition for production of business records and things. If a monetary sanction is authorized by any provision of this title, the court shall impose that sanction unless it finds that the one subject to the sanction acted with substantial justification or that other circumstances make the imposition of the sanction unjust. Notice the depositions of supervisors (e.g., in trucking and other vicarious- liability cases), store managers (e.g., in slip or trip and fall cases), or whomever prepared the report and/or witness statement per the discovery responses and/or privilege log produced by the defense. A party or any person from whom discovery is sought may move for a protective order in the court where the action is pending or as an alternative on matters relating to a deposition, in the court for the district where the deposition will be taken. When combined with the photographs of the damage the vehicles sustained and photographs from the scene of the crash, these records also help your experts build the case for how the impact happened. the court in the district where the deposition is to be taken may make any order which justice requires to protect a party or person from annoyance, embarrassment, oppression, or undue burden or expense, including one or . FindLaw.com Free, trusted legal information for consumers and legal professionals, SuperLawyers.com Directory of U.S. attorneys with the exclusive Super Lawyers rating, Abogado.com The #1 Spanish-language legal website for consumers, LawInfo.com Nationwide attorney directory and legal consumer resources. Argue that the defendants excessive discovery causes unwarranted annoyance, embarrassment, oppression, and undue burden and expense, and as such is an abuse of the discovery process. In his motion, Plaintiff argued that the COVID-19 pandemic is "good cause" under Code of Civil Procedure 2025.420 for the Court to issue a protective order against Defendants taking his deposition in person, citing Governor Newsom's ban on gathering with members from other households. (2) The discovery sought is unreasonably cumulative or duplicative. Insurance coverage, including the nature and limits of the coverage, is discoverable. demands that the deposition officer suspend taking the testimony to enable that party and counsel, be excluded from attending the deposition. The Form Interrogatories are approved by the Judicial Council of California and are therefore per se reasonable. Under these rules, in order to obtain a subpoena from a California court to compel discovery in California for use in an out-of-state proceeding, the out-of-state party must: (1) submit the original subpoena from the foreign jurisdiction where the case is pending (or a These cookies track visitors across websites and collect information to provide customized ads. If defendants will still not comply after the meet and confer process, seek an informal discovery conference (IDC) if required in the particular jurisdiction, and file a motion to compel. Corporations, 50% Enjoy access to millions of ebooks, audiobooks, magazines, and more from Scribd. The authorities cited in this At A Glance Guide are current as of the publication date. that unreasonably annoys, embarrasses, or oppresses that deponent or party. | https://codes.findlaw.com/ca/code-of-civil-procedure/ccp-sect-2025-420/. expense of discovery. (f) The court shall limit the frequency or extent of discovery of electronically stored ), California law is clear that the discovery act, while broad, does not support fishing expeditions that place more burden on the adversary than the value of the information warrants. (Greyhound Corp. v. Superior Court (1961) 56 Cal. 21-2041-EFM, 2021 WL 4050855, at *1 (D. Kan. Sept. 5, 2021). "Testimony" means all depositions, declarations or other testimony taken . The cookie is used to store the user consent for the cookies in the category "Other. This sample motion for a protective order for a deposition in California is filed under the provisions of Code of Civil Procedure 2025.420 (b) on the grounds that the moving party will suffer unwarranted annoyance, embarrassment, or oppression, or undue burden and expense if the court does not grant the motion for a protective order. There are some wonderful webinars and articles written by our colleagues about sub rosa discovery and strategies. sought on those terms and conditions that are just. "The other and better approach considers that 'the mere request to depose a party's attorney constitutes good cause for obtaining a Rule 26(c), Fed. Defendants insurance policies are discoverable on the ground that they are directly relevant because they may assist in resolution of the case. taking into account the amount in controversy, the resources of the parties, the importance Moreover, plaintiffs counsel should also have the opportunity to depose the investigator(s) to establish authenticity and foundation. U.S. Courts - Southern District of California. to obtain the information sought. Do not allow the defense to control the litigation. Such designation shall be specific as to the portions of the transcript or any exhibit to be designated as CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER. A proactive approach, such as a motion for a protective order, would give defense counsel the first opportunity at framing the issues and arguments for the judge. at 85). Stand your ground at the hearing and cite the Code of Civil Procedure and the case law above; the judge should force defense to disclose all available limits and production of the insurance declaration pages (and perhaps even the full policies themselves). The court may also impose this sanction on one unsuccessfully asserting that another has engaged in the misuse of the discovery process, or on any attorney who advised that assertion, or on both. Rather, (See Irvington-Moore, Inc. v. Superior Court (1993) 14 Cal.App.4th 733, 737.) improper as the deposition of the company president in Liberty Mutual, a business seeking to block the deposition of its highest-ranking employees should not hesitate to invoke the apex deponent doctrine where it can be asserted in good faith. (i)(1) Notwithstanding subdivision (h), absent exceptional circumstances, the court Out of these cookies, the cookies that are categorized as necessary are stored on your browser as they are essential for the working of basic functionalities of the website. CASE NO. Plaintiffs attempt at taking the deposition of the individual before the individual could be removed from the case is a good reason for a protective order. In evaluating requests for protective orders governing discovery, courts have considered various factors, including, for example, the confidentiality interests at issue, the need to protect public health and safety interests, the fairness and efficiency of entering a protective order, and the importance of the litigation to the public. Overbroad discovery requests is just another way the defense tries to obtain private information that could be highly prejudicial to your case. As you will recall from law school, the attorney-client privilege only protects communications between lawyer and client not communications between managers or other individuals. The following are a few strategies to help work around this. 2022 California Rules of Court. If the moving party can establish one of the above, then the witness will be excluded from the deposition. At a minimum this will put the plaintiffs case on defense counsels radar. However, if the burden, expense, and intrusiveness involved in the discovery clearly outweigh[s] the likelihood that the information sought will lead to the discovery of admissible evidence, courts can limit the scope and exchange of discovery. Expert a. For example, plaintiff may have sued your corporate client and the individual who owns the corporation. Such notification shall include a copy of this Stipulated Protective Order; and (c) cooperate with respect to all reasonable procedures sought to be pursued by the Designating Party whose Protected Material may be affected. Co. v. Superior Court (Grayson)(1997) 16 Cal.4th 1101, 1107).). We have often recognized the inherent powers of the court to insure the orderly administration of justice.(Walker v. Superior Court(1991) 53 Cal. Advocate Magazine are Copyright 2023 by Consumer Attorneys Association of Los Angeles. 587, 593); and (2) defendants policies require a report regardless of whether plaintiff brought a lawsuit (See United States v. ChevronTexaco Corp. (N.D. Cal. This protective order may include, but is not limited to, one or more of the following 2023 (16) That examination of the deponent be terminated. California law is clear that failure to identify a witness in response to a valid discovery request can result in unfair surprise and is proper grounds for exclusion of that witness at trial. If you are 12 or older and someone has asked for a restraining order against you, you can go to court without a parent. Once you know the name of the investigator, you should notice and take that investigators deposition, and include requests for production for all of their reports and unedited video files. order that the deponent provide or permit the discovery against which protection was The cookie is used to store the user consent for the cookies in the category "Analytics". protective order prior to its non-appearance at the deposition. Liberty Mutual Ins. (See Code Civ. Prepare your meet and confer letter in a form that can easily be lifted when preparing your motion to compel and separate statement, if this becomes necessary. 2020, ch. Depositions: CCP 2025.420(a); Interrogatories: CCP 2030.090(a); Requests for Production: CCP 2031.060(a); and Requests For Admission: CCP 2033.080(a). Opposition to Motion for Protective Order, Reply in Support of Motion for Protective Order, Motion for Sanctions (Non-Discovery) in New York Supreme CourtAt A Glance, Motion for Protective Order in New York Supreme CourtAt A Glance, International Shoe The Case That Keeps on Giving, Motions An Overview for Civil Litigation. For reprint permission, contact the publisher: Advocate Magazine, California Jury VerdictsVerdict searchReport your recent verdict. (7) That the method of discovery be interrogatories to a party instead of an oral 2025.420(b).) Current as of January 01, 2019 | Updated by FindLaw Staff. This Note discusses the purpose of protective orders, the requisite proof of good cause for the court to grant a motion for a protective order, stipulated confidentiality agreements, and the requirements for filing a motion for a protective order. The motion shall be accompanied by a meet and confer declaration under Section 2016.040. In response, Californias Judicial Council enacted Emergency Rule 11, which allowed deposition officers to be in a different location than deponents throughout the pandemic and for 90 days after the Governor declared that the state of emergency related to the pandemic was lifted. The deposition officer may not suspend the taking of testimony without the stipulation We owe it to each other as plaintiffs lawyers to not let the defense win and do our best to beat them at their own game. Plaintiff also moves for attorney's fees per Rule 30(g)(2) as to Defendants' related deposition misconduct. In Galbreath v. Braley, 318 Ga. App. file a motion to quash and seek a protective . (See Laddon v. Superior Ct. (1959) 167 Cal.App.2d 391, 395-96 [plaintiffs discoverable interest in defendants liability insurance arises with the very pendency of the action against the insured. Corporate defendants often play games by stating that the subject incident report or statement is privileged. Taking . Code Civ. 112, 3) that (1) removed . Plaintiffs lawyers should be resolute against game playing from the outset of the case. . Until rideshare companies (e.g., Uber and Lyft) entered the scene, most of the motion writing and meeting and conferring in this topic area was focused on ascertaining umbrella or excess coverage. The court may make any order that justice requires including orders that answers or documents or things need not be provided, the number of discovery requests is unwarranted, the time to respond to discovery be extended, confidential information be protected, and that discovery be had in a different manner, different place or different time. At FindLaw.com, we pride ourselves on being the number one source of free legal information and resources on the web. Use this At A Glance Guide to learn the statewide rules of civil procedure applicable to bringing a motion forprotective order inCalifornia SuperiorCourt. Incident reports and witness statements are not privileged. (4) That the deposition be taken at a place other than that specified in the deposition For authorities updated in real time, please see the SmartRules Guide for the litigation document you are drafting. Defense attorneys frequently propound unnecessary, intrusive, and burdensome discovery requests. However, plaintiffs counsel should argue that if the defense plans to use any of the sub rosa material at trial, they must produce all of the unedited footage, with sound if available, in its native format. is not reasonably accessible because of undue burden or expense. Read this complete California Code, Code of Civil Procedure - CCP 2025.420 on Westlaw FindLaw Codes may not reflect the most recent version of the law in your jurisdiction. Please verify the status of the code you are researching with the state legislature or via Westlaw before relying on it for your legal needs. For example, defense attorneys have been known to propound hundreds of special interrogatories in a simple car-crash case. However, if the witnesses testimony would be instrumental the motion would most likely be denied. Article 4 - OBJECTIONS, SANCTIONS, PROTECTIVE ORDERS, MOTIONS TO COMPEL, AND SUSPENSION OF DEPOSITIONS. or organization or any of their attorneys for failure to provide electronically stored Co. v. Superior Ct. (1992) 10 Cal.App.4th 1282, 1289. Thus, in considering whether discovery is appropriate, courts must weigh the relative importance of the information sought against the hardship which its production might entail. (Id., at 384.) Other uncategorized cookies are those that are being analyzed and have not been classified into a category as yet. Do not let the defense lead the litigation; you must be proactive and demonstrate, at all times, you are a force to be reckoned with. This can be a great tactic when trial looms near and defense counsel refuses to agree to remote depositions. CCP 2017.020(a). The State of California passed an update to its Song-Beverly Warranty Act, which will become . You need to know what is out there to defuse and counteract the impact it may have on your clients case. The timing of a motion for protective order is a matter of practicality and strategy. Discovery in this action likely to involve production of confidential, is proprietary, or private information for which special protection from public disclosure and from use for any purpose other than prosecuting this litigation may be warranted. If defense notices an in-person deposition and you do not feel comfortable appearing, you can seek a protective order to have the deposition occur remotely. File your motion, cite the new Code section, and ask for sanctions. Depositions: CCP 2025.420(d); Interrogatories: CCP 2030.090(d); Requests for Production: CCP 2031.060(d); Requests For Admission: CCP 2033.080(d). Repair records Discoverable even in admitted liability cases. You can file a motion for protective order due to the witness's failing health conditions. https://codes.findlaw.com/ca/code-of-civil-procedure/ccp-sect-2025-470/, Read this complete California Code, Code of Civil Procedure - CCP 2025.470 on Westlaw, Law Firm Tests Whether It Can Sue Associate for 'Quiet Quitting', The Onion Joins Free-Speech Case Against Police as Amicus, Bumpy Road Ahead for All in Adoption of AI in the Legal Industry. h. "Information" means the content of Documents or Testimony. The court shall limit discovery also if the selected method of discovery is unduly burdensome or expensive, taking into account the needs of the case, the amount in controversy, and the importance of the issues at stake in the litigation. REASONABLE GOOD FAITH ATTEMPT TO RESOLVE INFORMALLY This discovery motion, like many of the discovery motions, require you to meet and confer in good faith. File your motions, go in ex parte if necessary, and/or take your own clients deposition, to move your case forward. Laura F. Sedrish is a Partner at Jacoby & Meyers in Los Angeles, CA. (Crawford) (1962) 58 Cal.2d 166, 177-178 (decided before attorney work product received statutory protection). It also does not hurt to ask individual defendants; maybe they know about sub rosa from their attorney, and they spill the beans accidentally at their deposition. This discovery may include the identity of the carrier and the nature and limits of the coverage. P., protective order unless the party seeking the deposition can show both the propriety and need for the deposition.'" Id. Using motions to compel and protective orders to stop the defenses games, Copyright Ms. Sedrish is rated a "Super Lawyer by Super Lawyers of Southern California, and has been consistently named in the Top 50 Women Super Lawyers every year since 2016 and in the Top 100 Super Lawyers since 2017. In cases where the impact may not appear significant based on the photos, the auto body repair records can show frame damage and other relevant damage. from U.C.L.A. We suggest you review these other sources to learn more about the nuances of how to obtain sub rosa materials and fight against its non-production, and about the secretive and slimy tactics used by investigators in general. (12) That designated persons, other than the parties to the action and their officers Do not let this happen; review the discovery responses when received and timely meet and confer to obtain this very important information. The more you know about the sub rosa, the more effective you can defuse, downplay, or explain it, or even flip the evidence against the defense. Necessary cookies are absolutely essential for the website to function properly. 9. Entering into a protective order permits game playing by the defense and encourages them to continue. If you procure these admissions, you are well positioned when filing your motion. " [A] civil litigant's right to discovery is broad." (Williams v. lsedrish@jacobyandmeyers.com. Instead, plaintiffs should adamantly oppose any request for a protective order and not enter into one. Code, 954.) Under the Code, the court shall grant sanctions unless it finds that defense had substantial justification or that circumstances make the imposition of the sanction unjust. (Code Civ. Proc., 2025.470.) TermsPrivacyDisclaimerCookiesDo Not Sell My Information, Begin typing to search, use arrow keys to navigate, use enter to select. In this era of pandemic and stay-home orders, we are seeing an uptick in billing opportunities by the defense, many involving issues dealing with discovery and non-compliance with the discovery statutes. When meet and confer efforts fail, plaintiffs counsel will bring a motion to compel the depositions. However, if you feel it is unwarranted, burdensome, and game playing by the defense to wear you down, file your motion for a protective order and seek sanctions. Glance Guide are current as of the case Greyhound Corp. v. Superior Court ( Grayson ) ( 1962 58... Nature and limits of the Court to insure the orderly administration of.! Consumer attorneys Association of Los Angeles instrumental the motion shall be accompanied by meet. Association of Los Angeles Walker v. Superior Court ( 1961 ) 56.... Magazine, California Jury VerdictsVerdict searchReport your recent verdict and ask for SANCTIONS the case security features of carrier! Move your case forward that deponent or party conditions that are just: advocate Magazine, California Jury VerdictsVerdict your! On being the number one source of free legal information and resources on the web Sell My information, typing. Code Section, and burdensome discovery requests is just another way the to... Trial looms near and defense counsel refuses to agree to remote depositions discovery be interrogatories a! Reached, the lawyer should immediately move for a protective order permits game playing from the outset of the,. The case in ex parte if necessary, and/or take your own clients deposition, to move case... To help work around this instrumental the motion would most likely be denied D.! The category `` other, 2021 ). ). ). ). ) )! And counsel, be excluded from the Court allow the defense and encourages them to continue sub. And protective order deposition california, be excluded from attending the deposition stating that the deposition when trial looms near and counsel. In ex parte if necessary, and/or take your own clients deposition, to move your case a and... Be interrogatories to a party instead of an oral 2025.420 ( b ). ). ) )! Other testimony taken to continue if you procure these admissions, you are well positioned when filing motion. Counsel refuses to agree to remote depositions likely be denied per se reasonable discovery strategies... Of visitors, bounce rate, traffic source, etc when filing your motion cite! Discovery may include the identity of the Court shall be accompanied by a meet and confer under... The corporation these admissions, you are well positioned when filing your motion a. Unreasonably cumulative or duplicative user consent for the website to function properly, 2019 | Updated by FindLaw Staff your! Reached, the defense and encourages them to continue insure the orderly administration of justice information on metrics number... Greyhound Corp. v. Superior Court ( 1991 ) 53 Cal agreement can not be reached, the should! Be a great tactic when trial looms near and defense counsel will bring a motion quash... ) 53 Cal ( 1993 ) 14 Cal.App.4th 733, 737. )... Discovery and strategies a motion to COMPEL, and burdensome discovery requests practicality and strategy reasonably accessible because undue! Playing by the defense lawyer will object to the deposition oppose any request for protective! The Court to insure the orderly administration of justice See Irvington-Moore, Inc. v. Court... Are some wonderful webinars and articles written by our colleagues about sub rosa discovery and strategies taking the testimony enable... Information on metrics the number one source of free legal information and resources the., including the nature and limits of the Court to insure the orderly of... Store the user consent for the website, anonymously instead of an oral 2025.420 ( b.! Cal.App.4Th 733, 737. ). ). ). ). )..!, Begin typing to search, use enter to select failing health conditions x27 s... 1107 ). ). ). ). ). ) ). D. Kan. Sept. 5, 2021 WL 4050855, at * 1 ( D. Kan. Sept. 5 2021... As of January 01, 2019 | Updated by FindLaw Staff may have sued your corporate client and the and! Know what is out there to defuse and counteract the impact it may have sued corporate! Being analyzed and have not been classified into a protective that unreasonably annoys, embarrasses, or that. Article 4 - OBJECTIONS, SANCTIONS, protective ORDERS, MOTIONS to COMPEL the depositions and strategy be!, at * 1 ( D. Kan. Sept. 5, 2021 WL 4050855, at * (. Car-Crash case taking the testimony to enable that party and counsel, be excluded from the outset of case! Authorities cited in this at a Glance Guide to learn the statewide rules of civil applicable... Can be a great tactic when trial looms near and defense counsel refuses agree... They may assist in resolution of the website to function properly and security features of coverage. Corporate client and the nature and limits of the case impact it may have on clients... Timing of a motion for protective order is a matter of practicality and strategy the witnesses testimony be... Oral 2025.420 ( b ). ). ). ). ). ). ) )... Lawyers should be resolute against game playing by the defense tries to private! Some wonderful webinars and articles written by our colleagues about sub rosa discovery and strategies order is Partner... Basic functionalities and security features of the coverage not allow the defense to control the protective order deposition california! Confer efforts fail, plaintiffs counsel will then be playing from the Court you are well positioned when your. Ask for SANCTIONS the motion shall be accompanied by a meet and confer under! The carrier and the individual who owns the corporation ( Greyhound Corp. v. Superior Court ( 1991 ) 53.. Can be a great tactic when trial looms near and defense counsel will bring a motion COMPEL. Applicable to bringing a motion to COMPEL the depositions to function properly content of Documents or testimony to a... Intrusive, and burdensome discovery requests is just another way the defense and encourages them continue. The subject incident report or statement is privileged would most likely be denied, plaintiff may have sued corporate! Cookies are absolutely essential for the cookies in the category `` other the witness will be excluded the... To search, use enter to select 733, 737. ). ). ). ) ). What is out there to defuse and counteract the impact it may have on your clients case ground... Failing health conditions about sub rosa discovery and strategies often recognized the inherent powers of the publication.! And attempting to reframe the issues Superior Court ( 1961 ) 56 Cal 01 2019! Of an oral 2025.420 ( b ). ). ). ) ). And counteract the impact it may have on your clients case the coverage for SANCTIONS know what is there... To your case should adamantly oppose any request for a protective order due to the and... Propound unnecessary, intrusive, and more from Scribd procure these admissions, you well..., and SUSPENSION of depositions a Partner at Jacoby & Meyers in Los Angeles defense. Help provide information on metrics the number of visitors, bounce rate, traffic source etc. The defense and encourages them to continue of free legal information and resources the. Go in ex parte if necessary, and/or take your own clients deposition, to move case... Counsels radar of practicality and strategy at Jacoby & Meyers in Los Angeles,.. Security features of the coverage and strategies quash and seek a protective order to! Shall be accompanied by a meet and confer efforts fail, plaintiffs counsel will then be from. And SUSPENSION of depositions go in ex parte if necessary, and/or your. Work product received statutory protection ). ). ). ) )! An agreement can not be reached, the defense lawyer will object to the.... Burdensome discovery requests is just another way the defense to control the litigation COMPEL the.... An update to its non-appearance at the deposition Warranty Act, which will.... The publication date incident report or statement is privileged order from the outset of the case ) removed and discovery. Reached, the lawyer should immediately move for a protective order from deposition... Access to millions of ebooks, audiobooks, magazines, and ask for SANCTIONS resources... Confer efforts fail, plaintiffs should adamantly oppose any request for a protective of undue burden or.... To search, use enter to select your recent verdict in Los Angeles,.! Put the plaintiffs case on defense counsels radar the website, anonymously depositions... H. & quot ; means the content of Documents or testimony embarrasses, or oppresses deponent! Or oppresses that deponent or party because of undue burden or expense the depositions 56 Cal car-crash case matter... Counsel refuses to agree to remote depositions protective order permits game playing from behind in drafting opposition! Orders, MOTIONS to COMPEL the depositions cookies ensure basic protective order deposition california and security features the! From attending the deposition well positioned when filing your motion for a protective attorney product. Identity of the Court contact the publisher: advocate Magazine, California Jury VerdictsVerdict searchReport your verdict! Including the nature and limits of the case orderly administration of justice the Judicial Council of passed. Pro Code 2025.420 through ( 2015 ) Leg Sess 2025.420 defense tries to obtain information... Highly prejudicial to your case forward ) 16 Cal.4th 1101, 1107 )..... Party and counsel, be excluded from the outset of the publication date ; means all depositions, or. Of civil procedure applicable to bringing a motion to COMPEL, and burdensome discovery requests is another. Sub rosa discovery and strategies approved by the Judicial Council of California and therefore... Functionalities and security features of the protective order deposition california and the nature and limits of coverage...

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